Access the on-demand series here.

Part 1: The CMS Vaccine Mandate – Compliance Requirements and Challenges for Health Centers

On November 4, 2021, the Centers for Medicare & Medicaid Services (CMS) issued an Interim Final Rule (IFR) requiring that health care workers at Medicare and Medicaid-certified facilities be vaccinated. It is estimated that more than 10,000 Federally Qualified Health Center sites will be covered by the CMS IFR. The IFR does not include a vaccine-or-test option; however, employees may request a religious or medical exemption and, if granted, employers must provide a reasonable accommodation. 

By December 6, 2021, covered facilities must develop and implement the required policies and procedures which must include the mandatory vaccination policy, tracking and securely documenting vaccination status and booster doses for all staff, and requesting a medical or religious exemption. The IFR also requires that all staff must receive a single dose COVID-19 vaccine or the initial does of a primary series by December 6, 2021.  

By January 4, 2022, all applicable staff must be fully vaccinated for COVID–19, except for those staff who have been granted exemptions from COVID–19 vaccination or those staff for whom COVID–19 vaccination must be temporarily delayed, as recommended by the CDC, due to clinical precautions and considerations.

As legal challenges threaten and the compliance deadlines loom, join FTLF for Part 1 of this webinar series which will include in-depth look at the CMS IFR that will provide information on whether the IFR applies to various types of employees, vendors, and volunteers (including Board members); suggestions on how to incorporate the IFR requirements into your health center’s policies and procedures (and whether to seek Board approval); and an expanded FAQ section based on questions received from health centers across the country.

Part 2:  Responding to Medical and Religious Exemption and Accommodation Requests

Under federal law, some health center staff members may be exempt from a health center’s vaccine mandate pursuant to the reasonable accommodation provisions of Title VII of the Civil Rights Act of 1964 (Title VII) and the Americans with Disabilities Act (ADA). There are two types of exemptions:

• Religious exemptions for sincerely held religious beliefs, practices, and observances; and
• Medical exemptions for certain disabilities.

Health centers must engage in an interactive process with employees to analyze exemption requests and, when an exemption is granted, to determine whether there is a reasonable accommodation that the health center can provide. Notably, the CMR IFR includes additional documentation requirements for medical exemption requests from staff members.

Navigating the process for analyzing exemptions and providing accommodations can be difficult and costly for health centers.  

As health centers receive and respond to exemption requests related to the vaccine mandates required under the CMS IFR, join FTLF for Part 2 of this webinar series in which we will explore best practices for handling exemption requests - from documenting the interactive process to the confidentiality requirements around the information received from employees.

Please note: This webinar series is offered at a discounted price of $300 for all Health Center Compliance 2021 Premium Plan Subscribers. For more information on our Premium Plan, click here or Contact Us.